ITDS Annual Report Recommends Basic Functions be Implemented Using ABI

(ITDS, which is a part of ACE, is an interagency effort to eliminate redundant reporting by creating a "single-window" system, replacing multiple filings (often on paper) with a single electronic filing. Relevant data would be distributed electronically to the appropriate agencies, providing them with the ability to process that data electronically.)

Highlights of the report's Executive Summary pertaining to ITDS include the following (see future issues of ITT for further details on the report):

Scheduled ITDS Functionality Not Delivered Due to ACE Delays

The past year has seen a significant delay in implementation of the ACE Vessel and Rail Manifest Release (M1 Release). ITDS functionality scheduled for this release has therefore not been delivered. More importantly, the planning² for other subsequent releases has also been delayed.

The lack of a clear and stable schedule for ACE development has made it difficult for ITDS agencies to plan for their future operations with ACE and to plan investments in their own IT systems. There is concern that the agencies would lose the knowledge and expertise they have developed in preparing to implement ITDS, or plans would be interrupted or abandoned, if ITDS implementation is subject to further lengthy delays or interruptions.

Some Agencies Consider Using Own Parallel Systems to Collect Importer Data

In addition, the delay is causing some agencies to consider using their own systems for collecting data from importers. These would operate in parallel with CBP collections, and be inconsistent with the single-window concept of the SAFE Port Act. One agency - the Food Safety Inspection Service - has already made the decision to develop, although as an interim measure, the ability to electronically collect data directly from importers pending progress on ACE.

(FSIS is building a system, scheduled to come on line in October 2010, to accept electronic data on imports of food products containing meat, poultry, and egg products, which it would process electronically, and upon completion of the mandatory inspection, then send an electronic message to CBP with directions on whether to release a shipment or not. This web-based capability would accept information directly from traders about those importations. FSIS plans to use that capability on an interim basis to receive information on imports into the customs territory pending delivery of ITDS functionality through ACE.)

CBP Considering Alternative Approach to Provide Basic ITDS Functions

CBP is currently considering an alternative approach that would mitigate the delays, providing quicker implementation of basic ITDS functions.

Use of ABI. Instead of waiting for deployment of future ACE releases, CBP could immediately begin to collect ITDS data for other agencies through ABI (Automated Broker Interface) - the data intake module for both ACE and ACS, CBP's current trade processing system - and then made that data available to agencies through the ACE Data Warehouse.

Because the same input system (ABI) used for ACS is also to be used for ACE, there would be no duplication of cost with regard to programming the added data elements. The added data would have to be stored in ACE under either scenario, although the provision of storage capacity in ACE would have to be accelerated in order to provide immediate access to the data. CBP is attempting to estimate these costs but that work has not been completed.

Program for 'imaged' forms. In addition to collecting new data through ABI, CBP could provide for transmission of "imaged" forms (such as .pdf files). For some seldom used paper forms this could be a permanent solution, but for other data that would most effectively be collected through electronic data interchange (EDI), this approach could still provide significant short-term benefits. For example, in some cases, "imaging," even if done only on an interim basis, could speed delivery of information to the appropriate agencies and would provide the additional advantage to CBP of allowing remote location filing for entries that currently require the filing of supplemental paper forms.

No New ITDS Functionality Was Added Over Past Year

According to the report, some ITDS functions are already operational. Agencies already can obtain from CBP some import data that is collected electronically. Some agencies have used that data to interdict shipments and also to eliminate paperwork requirements. However, even the limited ITDS functionality currently available is not yet being fully utilized by all ITDS agencies. Moreover, no new ITDS functionality has been added over the past year.

Forty-seven Federal agencies (including CBP) currently participate in the ITDS Program. All agencies required to participate in ITDS by the SAFE Port Act have joined the program. Most agencies participating in ITDS must develop a plan ("Concept of Operations") describing how the agencies will operate when ITDS is implemented.

While some agencies have a well developed plan for automating their business processes and have completed preparations to receive and use data, other agencies are at an earlier stage of planning. Some agencies have been unable to commit budget and staff to ITDS; others have been reluctant to commit resources to an information technology system outside the control of their own agency.

CBP developing own plan. CBP has recently decided to undertake a general review of its own plans for operating with ITDS, in other words, it is developing a CBP Concept of Operations. This work, slated for completion by December 2009, should put CBP in a better position to made decisions awaited by other agencies in order to continue with their own planning for ITDS.

Report Lists its Recommendations for CBP

The report makes the following recommendations for CBP:

1. CBP should immediately add data elements required by other agencies to the major import reporting messages (manifest, entry, entry summary) in order to:

Make import safety agencies better able to interdict unsafe shipments,

Prevent proliferation of parallel systems for reporting imports,

Prevent loss of agency expertise with regard to ITDS, and

Ensure basic ITDS functionality is built and not dropped in favor of other priorities.

1. CBP should develop the capability to accept transmission of "imaged" forms (such as .pdf files) which may currently only be submitted on paper. As an interim measure, pending the development of a full electronic data interchange between agencies, this would speed delivery of information to offices still using paper and would allow CBP to provide paperless filing for entries that now require paper forms.
2. CBP should complete its plans for ITDS and make decisions related to the technical interoperability with other agencies' systems, in order to allow other agencies to continue with their plans and investments in automated systems for using ITDS.

¹The "Security and Accountability for Every Port Act of 2006" (P.L. 109-347)

²Contract support for ITDS planning has been greatly reduced and may not be extended beyond December 2009.

ITDS report (not posted on ITDS website) available by emailing documents@brokerpower.com